
The Future of Transferable Tax Credits: What Businesses Need to Know
Changing Landscape for Clean Energy Incentives
In recent months, the future of transferable tax credits has become increasingly uncertain. Legislative developments in Washington are putting pressure on key tax provisions introduced under the Inflation Reduction Act—particularly the clean energy investment tax credits (ITCs) and production tax credits. A bill passed by the House on May 22 proposes eliminating taxpayers’ ability to transfer several of these credits under Section 6418. However, the Senate’s version of the bill, released on June 16, retains these transferability provisions—highlighting their popularity across industries. The transferability feature was introduced to allow a broader base of corporate taxpayers to participate in the tax equity market. This move opened the door for corporations outside of banking and finance—such as manufacturers and service providers—to leverage clean energy incentives, even if they lacked the immediate tax appetite to do so directly. As Congress considers sunsetting these programs, the business community is asking an important question: could other tax credits become transferable? According to tax professionals, the answer could have significant implications for industries far beyond renewable energy.New Frontiers: Transferability Beyond Clean Energy
States have long used transferable tax credits to drive investment in targeted sectors. With a federal framework now in place to administer such credits through the IRS, the door is open for new categories of transferable incentives. Several proposals now circulating in Congress aim to extend these credits to sectors like agriculture, infrastructure, and manufacturing. Below are some noteworthy examples:Supporting Agricultural Innovation
H.R. 1705 – Supporting Innovation in Agriculture Act of 2025 proposes a 30% transferable ITC for investments in forward-thinking agricultural technologies. The bill’s definition of “qualified property” includes both tangible personal property and software that supports innovative agricultural projects. Examples of eligible projects include:- Controlled Environment Agriculture (CEA): Indoor farming systems like hydroponics and vertical farming, where environmental conditions are carefully managed.
- Precision Agriculture Technologies: Use of drones, robotics, sensors, and data analytics to increase farming efficiency.
Strengthening the Electric Grid
America’s electrical grid is facing growing demands from population growth and clean energy adoption. In response, Congress has introduced several grid-focused bills to modernize transmission infrastructure:- H.R. 5803 – Grid Resiliency Tax Credit Act: Offers a 30% transferable ITC for transmission projects that improve reliability and grid capacity.
- H.R. 6747 – Clean Electricity and Transmission Acceleration Act: Provides a base 6% ITC (up to 30% with wage and apprenticeship bonuses) and includes permitting reforms for high-priority transmission projects.
Rebuilding Critical Supply Chains
The pandemic spotlighted vulnerabilities in the U.S. supply chain. To address this, H.R. 8504 – Supply Chain Security and Growth Act proposes a 40% transferable ITC for companies reshoring critical manufacturing operations in industries such as:- Biotechnology
- Pharmaceuticals
- Semiconductors
- Aerospace